`
`Exhibit B-2 - Preliminary Invalidity Contentions - U.S. Patent No. 9,561,439 to Oono
`Based on U.S. Patent Pub. No. 2011/0300926 to Englman et al. (“Englman”)
`
`The following chart contains Supercell’s Invalidity Contentions demonstrating that Englman anticipates Claims 1-7 of U.S. Patent No.
`9,561,439 under 35 U.S.C. § 102 or renders the same claims obvious alone or in view of other prior art under 35 U.S.C. § 103. Because
`the Court has yet to issue a claim construction in this case, fact discovery is ongoing, and the invalidity of the asserted claims will likely
`be the subject of expert discovery, these contentions are preliminary only and Supercell reserves the right to supplement or modify these
`contentions in accordance with the agreed patent-disclosure procedures and the Docket Control Order in this case. Additionally, and in
`further consideration of the preliminary stages of the case, Supercell notes that the pinpoint citations referenced in this chart are not
`exhaustive, and Supercell reserves the right to rely on additional citations within the reference. Furthermore, citations to any figure,
`table, or chart are meant to encompass the language describing the respective figure, table, or chart, and vice versa.
`
`These charts also incorporate analysis based upon GREE’s apparent interpretation of the asserted claims, as reflected in GREE’s
`infringement contentions to date. Supercell does not agree with GREE’s incomplete, ambiguous, and inadequate application of the
`asserted claims in those contentions. However, as detailed below, such application (to the extent that it can be reasonably ascertained)
`further renders each asserted claim invalid. Supercell further reserves its right to supplement these contentions based on further
`discovery, including any supplemental infringement contentions or any interrogatory response purporting to rebut these invalidity
`contentions provided by GREE.
`
`Additionally, Supercell notes that while certain potential obviousness arguments and combinations may be cited within these charts,
`such recitations are not exhaustive. As such, to the extent that any asserted claims are found not to be anticipated by Englman, Supercell
`reserves the right to argue that such non-anticipated claims are obvious over Englman alone, in view of any of the arguments raised
`within the charts, in view of any of the other prior art cited in Supercell’s cover pleading, or in view of prior art that may later become
`known to Supercell as part of the discovery process.
`
`
`
`
`
`
`
`
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 1 of 32
`
`

`

`
`
`’439 Patent Claim 1
`
`[Preamble]
`A game control method
`carried out by a game control
`device for providing a game
`to a plurality of
`communication terminals
`respectively used by a
`plurality of users, the game
`control device
`communicating with the
`plurality of communication
`terminals over a
`communication network and
`having a storage unit for
`storing information for each
`of the plurality of users, the
`method comprising the steps
`of:
`
`
`
`Disclosure from Englman
`
`Englman discloses a game control method carried out by a game control device for providing a game
`to a plurality of communication terminals respectively used by a plurality of users, the game control
`device communicating with the plurality of communication terminals over a communication network
`and having a storage unit for storing information for each of the plurality of users.
`
`“In FIG. 1, a wagering game system (“system”) 100 includes a wagering game server 150 connected
`to one or more client devices, such as a wagering game machine 160 or a computer 137, via a
`communications network 122.” ¶ [0045]
`“The wagering game system architecture 200 can also include a wagering game server 250
`configured to present wagering games and receive and transmit information to present group games
`and awards. The wagering game server 250 can include a content controller 251 configured to
`manage and control content for the presentation of content on a client device (“client”) 260… The
`wagering game server 250 can also include a content store 252 configured to contain content to
`present on the client 260.” ¶ [0049]
`“FIG. 9 is a conceptual diagram that illustrates an example of a wagering game machine architecture
`900, according to some embodiments… The I/O bus 922 is connected to a payout mechanism 908,
`primary display 910, secondary display 912, value input device 914, player input device 916,
`information reader 918, and storage unit 930.” ¶ [0122]
`
`To the extent this limitation is not explicitly disclosed, Supercell responds that it is inherent or
`obvious. Moreover, it would have been obvious to one of ordinary skill in the art to modify this
`reference so as to include this claim limitation in light of the knowledge possessed by one of ordinary
`skill in the art. Further, this claim limitation would have been obvious in light of numerous other U.S.
`patents, U.S. patent publications, articles, and products available at the time the asserted patent was
`filed, and it would have been obvious to combine these references to a person of ordinary skill in the
`art. For example, see at least the corresponding claim elements in the respective charts, which are
`
`2
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 2 of 32
`
`

`

`’439 Patent Claim 1
`
`[Element 1-A]
`(a) grouping the plurality of
`users into one or more
`groups;
`
`
`
`Disclosure from Englman
`incorporated by reference as if fully set forth herein: World of Warcraft, Warhammer Online, Guild
`Wars 2, Ronen, Qiang, Bethke, Kane, Kobayashi, Forsaken World.
`
`Englman discloses (a) grouping the plurality of users into one or more groups.
`
`“The account server 270 can also include an account store 272 configured to store information,
`settings, preferences, etc. for a player's account, group scavenger hunt game membership, scavenger
`hunt game progress, collected scavenger hunt items, item exchanges, trophy possession rights, trophy
`benefits, etc.” ¶ [0048]
`“In FIG. 3, the flow 300 begins at processing block 302, where a wagering game system (“system”)
`registers a player account as a group member to compete in a group scavenger hunt game. The
`system can present a themed scavenger hunt game. The scavenger hunt game can be a group game,
`where a group of player accounts join together to form a scavenger hunt group. In some
`embodiments, the system can facilitate creating groups by connecting player accounts and presenting
`controls where players can form a group amongst their friends, family, or other social contacts listed
`in the player account.” ¶ [0060]
`
`To the extent this limitation is not explicitly disclosed, Supercell responds that it is inherent or
`obvious. Moreover, it would have been obvious to one of ordinary skill in the art to modify this
`reference so as to include this claim limitation in light of the knowledge possessed by one of ordinary
`skill in the art. Further, this claim limitation would have been obvious in light of numerous other U.S.
`patents, U.S. patent publications, articles, and products available at the time the asserted patent was
`filed, and it would have been obvious to combine these references to a person of ordinary skill in the
`art. For example, see at least the corresponding claim elements in the respective charts, which are
`incorporated by reference as if fully set forth herein: World of Warcraft, Warhammer Online, Guild
`Wars 2, Ronen, Qiang, Bethke, Kane, Kobayashi, Forsaken World.
`
`[Element 1-B]
`
`Englman discloses (b) storing a correspondence between the plurality of users and the one or more
`groups in the storage unit.
`
`3
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 3 of 32
`
`

`

`’439 Patent Claim 1
`(b) storing a correspondence
`between the plurality of users
`and the one or more groups in
`the storage unit;
`
`
`
`Disclosure from Englman
`“The account server 270 can also include an account store 272 configured to store information,
`settings, preferences, etc. for a player's account, group scavenger hunt game membership, scavenger
`hunt game progress, collected scavenger hunt items, item exchanges, trophy possession rights, trophy
`benefits, etc.” ¶ [0048]
`“The CPU 926 is also connected to an input/output (“I/O”) bus 922, which can include any suitable
`bus technologies, such as an AGTL+ frontside bus and a PCI backside bus. The I/O bus 922 is
`connected to a payout mechanism 908, primary display 910, secondary display 912, value input
`device 914, player input device 916, information reader 918, and storage unit 930.” ¶ [0122]
`
`To the extent this limitation is not explicitly disclosed, Supercell responds that it is inherent or
`obvious. Moreover, it would have been obvious to one of ordinary skill in the art to modify this
`reference so as to include this claim limitation in light of the knowledge possessed by one of ordinary
`skill in the art. Further, this claim limitation would have been obvious in light of numerous other U.S.
`patents, U.S. patent publications, articles, and products available at the time the asserted patent was
`filed, and it would have been obvious to combine these references to a person of ordinary skill in the
`art. For example, see at least the corresponding claim elements in the respective charts, which are
`incorporated by reference as if fully set forth herein: World of Warcraft, Warhammer Online, Guild
`Wars 2, Ronen, Qiang, Bethke, Kane, Kobayashi, Forsaken World.
`
`[Element 1-C]
`(c) transmitting information
`over the communication
`network to initiate a group
`event in which a first plurality
`of users forming a first group
`cooperatively participate in
`the game;
`
`Englman discloses (c) transmitting information over the communication network to initiate a group
`event in which a first plurality of users forming a first group cooperatively participate in the game.
`
`“The progress report 103 can also show any events that need to be accomplished for items not yet
`obtained (e.g., see FIG. 4 which describes details about a missing item—Frodo's missing painting
`117). The progress report 103 can also present a game progress meter 105 that tracks the progress of
`the group scavenger hunt game. Multiple group scavenger hunt members can share the progress
`report 103. The system 100 can present group statistics 106 that relate to the group members'
`achievements. Each group member's achievements (e.g., obtaining an item) can contribute overall as
`
`4
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 4 of 32
`
`

`

`’439 Patent Claim 1
`
`
`
`Disclosure from Englman
`a group achievement in that everyone who shares the progress report 103 benefits from each
`member's achievements.
`The webpage 181 can include an online group-scavenger-hunt progress report (“progress report”)
`103. The progress report 103 can be a themed presentation, which group members of the group
`scavenger hunt game, and others, can visit via the Internet. A purpose of the progress report 103 can
`be to show various items (e.g., fireplace tools 107, flute 108, and pipe 109) that group members have
`collected for the group scavenger hunt game. The system 100 can present the items in a specific
`order, en route to an overall prize, like a trophy. ¶ [0045]
`
`
`5
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 5 of 32
`
`

`

`’439 Patent Claim 1
`
`Disclosure from Englman
`
`
`
`
`To the extent this limitation is not explicitly disclosed, Supercell responds that it is inherent or
`obvious. Moreover, it would have been obvious to one of ordinary skill in the art to modify this
`reference so as to include this claim limitation in light of the knowledge possessed by one of ordinary
`
`
`
`6
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 6 of 32
`
`

`

`’439 Patent Claim 1
`
`[Element 1-D]
`(d) storing a parameter value
`for each of the plurality of
`users, wherein the parameter
`value for a respective user is
`increased as the respective
`user makes progress in the
`group event;
`
`
`
`Disclosure from Englman
`skill in the art. Further, this claim limitation would have been obvious in light of numerous other U.S.
`patents, U.S. patent publications, articles, and products available at the time the asserted patent was
`filed, and it would have been obvious to combine these references to a person of ordinary skill in the
`art. For example, see at least the corresponding claim elements in the respective charts, which are
`incorporated by reference as if fully set forth herein: World of Warcraft, Warhammer Online, Guild
`Wars 2, Ronen, Qiang, Bethke, Kane, Kobayashi, Forsaken World.
`
`Englman discloses (d) storing a parameter value for each of the plurality of users, wherein the
`parameter value for a respective user is increased as the respective user makes progress in the group
`event.
`
`“The account server 270 can include an account controller 271 configured to control information for
`a player's account. The account server 270 can also include an account store 272 configured to store
`information, settings, preferences, etc. for a player's account, group scavenger hunt game
`membership, scavenger hunt game progress, collected scavenger hunt items, item exchanges, trophy
`possession rights, trophy benefits, etc.” ¶ [0048]
`“The system can attribute scores, levels, status, etc. on a personal trophy case for how many items the
`player obtained so that the player obtains satisfaction on a personal level. The system can utilize
`game scores, levels, status, etc. to perform better on triggering or obtaining items in some kinds of
`wagering games, such as bonus games, skill based wagering games, etc. (e.g., a level 5 group
`member may have a greater chance of obtaining certain items or performing well on certain items
`than a level 1 group member). … The system can provide players with tickets based on the number of
`items that a player account obtained during the group scavenger hunt game. By receiving more
`tickets, a player account would have a greater chance of winning the award. In some examples, if an
`item requires an event to be obtained multiple times, then the system could award tickets to player
`accounts based on the number of times that the player account completed the event for the item.
`Some tickets may be more valuable than others may (e.g., have values greater than one ticket).”
`¶ [0066]
`“In some embodiments, some achievements may be awarded based upon accumulation of other
`achievements or assets, such that the awarding of virtual assets is subject to a hierarchy. For example,
`
`7
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 7 of 32
`
`

`

`’439 Patent Claim 1
`
`
`
`Disclosure from Englman
`collecting achievements such as ribbons may permit a player to be awarded a higher-level
`achievement, such as a medal, in accordance with one or more rule sets. In an example, collecting ten
`ribbons provides a player with a medal as an achievement, while further still, collecting ten medals
`awards the player a trophy, as an achievement or asset. Such hierarchy may be provided to players in
`a number of ways, including via gaming terminals or over the internet. Moreover, the rules set(s) of
`the system may further govern which players may win higher-level achievements. For example, in an
`embodiment, only one player may win a trophy (a higher-level achievement) even though all players
`are eligible to win lower level achievements. The player winning the trophy may satisfy certain
`criteria, for example, being the first one to win a certain number of lower level achievements. Other
`criteria may be employed as well.” ¶ [0096]
`
`To the extent this limitation is not explicitly disclosed, Supercell responds that it is inherent or
`obvious. Moreover, it would have been obvious to one of ordinary skill in the art to modify this
`reference so as to include this claim limitation in light of the knowledge possessed by one of ordinary
`skill in the art. Further, this claim limitation would have been obvious in light of numerous other U.S.
`patents, U.S. patent publications, articles, and products available at the time the asserted patent was
`filed, and it would have been obvious to combine these references to a person of ordinary skill in the
`art. For example, see at least the corresponding claim elements in the respective charts, which are
`incorporated by reference as if fully set forth herein: World of Warcraft, Warhammer Online, Guild
`Wars 2, Ronen, Qiang, Bethke, Kane, Kobayashi, Forsaken World.
`
`[Element 1-E]
`(e) monitoring progress of the
`group event and updating the
`parameter value for each of
`the first plurality of users in
`accordance with the progress
`of the first group in the group
`event;
`
`Englman discloses (e) monitoring progress of the group event and updating the parameter value for
`each of the first plurality of users in accordance with the progress of the first group in the group
`event.
`
`“The account server 270 can include an account controller 271 configured to control information for
`a player's account. The account server 270 can also include an account store 272 configured to store
`information, settings, preferences, etc. for a player's account, group scavenger hunt game
`
`8
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 8 of 32
`
`

`

`’439 Patent Claim 1
`
`
`
`Disclosure from Englman
`membership, scavenger hunt game progress, collected scavenger hunt items, item exchanges, trophy
`possession rights, trophy benefits, etc.” ¶ [0048]
`“The system can attribute scores, levels, status, etc. on a personal trophy case for how many items the
`player obtained so that the player obtains satisfaction on a personal level. The system can utilize
`game scores, levels, status, etc. to perform better on triggering or obtaining items in some kinds of
`wagering games, such as bonus games, skill based wagering games, etc. (e.g., a level 5 group
`member may have a greater chance of obtaining certain items or performing well on certain items
`than a level 1 group member). … The system can provide players with tickets based on the number of
`items that a player account obtained during the group scavenger hunt game. By receiving more
`tickets, a player account would have a greater chance of winning the award. In some examples, if an
`item requires an event to be obtained multiple times, then the system could award tickets to player
`accounts based on the number of times that the player account completed the event for the item.
`Some tickets may be more valuable than others may (e.g., have values greater than one ticket).”
`¶ [0066]
`“In some embodiments, some achievements may be awarded based upon accumulation of other
`achievements or assets, such that the awarding of virtual assets is subject to a hierarchy. For example,
`collecting achievements such as ribbons may permit a player to be awarded a higher-level
`achievement, such as a medal, in accordance with one or more rule sets. In an example, collecting ten
`ribbons provides a player with a medal as an achievement, while further still, collecting ten medals
`awards the player a trophy, as an achievement or asset. Such hierarchy may be provided to players in
`a number of ways, including via gaming terminals or over the internet. Moreover, the rules set(s) of
`the system may further govern which players may win higher-level achievements. For example, in an
`embodiment, only one player may win a trophy (a higher-level achievement) even though all players
`are eligible to win lower level achievements. The player winning the trophy may satisfy certain
`criteria, for example, being the first one to win a certain number of lower level achievements. Other
`criteria may be employed as well.” ¶ [0096]
`
`To the extent this limitation is not explicitly disclosed, Supercell responds that it is inherent or
`obvious. Moreover, it would have been obvious to one of ordinary skill in the art to modify this
`reference so as to include this claim limitation in light of the knowledge possessed by one of ordinary
`
`9
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 9 of 32
`
`

`

`’439 Patent Claim 1
`
`[Element 1-F]
`(f) providing at least one of a
`plurality of game pieces to
`each of the first plurality of
`users in the group event,
`based on the parameter value
`for the corresponding user,
`wherein the plurality of game
`pieces are required to obtain a
`game item;
`
`
`
`Disclosure from Englman
`skill in the art. Further, this claim limitation would have been obvious in light of numerous other U.S.
`patents, U.S. patent publications, articles, and products available at the time the asserted patent was
`filed, and it would have been obvious to combine these references to a person of ordinary skill in the
`art. For example, see at least the corresponding claim elements in the respective charts, which are
`incorporated by reference as if fully set forth herein: World of Warcraft, Warhammer Online, Guild
`Wars 2, Ronen, Qiang, Bethke, Kane, Kobayashi, Forsaken World.
`
`Englman discloses (f) providing at least one of a plurality of game pieces to each of the first plurality
`of users in the group event, based on the parameter value for the corresponding user, wherein the
`plurality of game pieces are required to obtain a game item.
`
` “The system can attribute scores, levels, status, etc. on a personal trophy case for how many items
`the player obtained so that the player obtains satisfaction on a personal level. The system can utilize
`game scores, levels, status, etc. to perform better on triggering or obtaining items in some kinds of
`wagering games, such as bonus games, skill based wagering games, etc. (e.g., a level 5 group
`member may have a greater chance of obtaining certain items or performing well on certain items
`than a level 1 group member). … The system can provide players with tickets based on the number of
`items that a player account obtained during the group scavenger hunt game. By receiving more
`tickets, a player account would have a greater chance of winning the award. In some examples, if an
`item requires an event to be obtained multiple times, then the system could award tickets to player
`accounts based on the number of times that the player account completed the event for the item.
`Some tickets may be more valuable than others may (e.g., have values greater than one ticket).”
`¶ [0066]
`“In some embodiments, some achievements may be awarded based upon accumulation of other
`achievements or assets, such that the awarding of virtual assets is subject to a hierarchy. For example,
`collecting achievements such as ribbons may permit a player to be awarded a higher-level
`achievement, such as a medal, in accordance with one or more rule sets. In an example, collecting ten
`ribbons provides a player with a medal as an achievement, while further still, collecting ten medals
`awards the player a trophy, as an achievement or asset. Such hierarchy may be provided to players in
`a number of ways, including via gaming terminals or over the internet. Moreover, the rules set(s) of
`
`10
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 10 of 32
`
`

`

`’439 Patent Claim 1
`
`[Element 1-G]
`(g) storing allocation
`information indicating which
`game piece has been provided
`to which user, in the storage
`unit;
`
`
`
`Disclosure from Englman
`the system may further govern which players may win higher-level achievements. For example, in an
`embodiment, only one player may win a trophy (a higher-level achievement) even though all players
`are eligible to win lower level achievements. The player winning the trophy may satisfy certain
`criteria, for example, being the first one to win a certain number of lower level achievements. Other
`criteria may be employed as well.” ¶ [0096]
`
`To the extent this limitation is not explicitly disclosed, Supercell responds that it is inherent or
`obvious. Moreover, it would have been obvious to one of ordinary skill in the art to modify this
`reference so as to include this claim limitation in light of the knowledge possessed by one of ordinary
`skill in the art. Further, this claim limitation would have been obvious in light of numerous other U.S.
`patents, U.S. patent publications, articles, and products available at the time the asserted patent was
`filed, and it would have been obvious to combine these references to a person of ordinary skill in the
`art. For example, see at least the corresponding claim elements in the respective charts, which are
`incorporated by reference as if fully set forth herein: World of Warcraft, Warhammer Online, Guild
`Wars 2, Ronen, Qiang, Bethke, Kane, Kobayashi, Forsaken World.
`
`Englman discloses (g) storing allocation information indicating which game piece has been provided
`to which user, in the storage unit.
`
`“The account server 270 can include an account controller 271 configured to control information for
`a player's account. The account server 270 can also include an account store 272 configured to store
`information, settings, preferences, etc. for a player's account, group scavenger hunt game
`membership, scavenger hunt game progress, collected scavenger hunt items, item exchanges, trophy
`possession rights, trophy benefits, etc.” ¶ [0048]
`“The CPU 926 is also connected to an input/output (“I/O”) bus 922, which can include any suitable
`bus technologies, such as an AGTL+ frontside bus and a PCI backside bus. The I/O bus 922 is
`connected to a payout mechanism 908, primary display 910, secondary display 912, value input
`device 914, player input device 916, information reader 918, and storage unit 930.” ¶ [0122]
`
`11
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 11 of 32
`
`

`

`’439 Patent Claim 1
`
`
`
`Disclosure from Englman
`“The system can attribute scores, levels, status, etc. on a personal trophy case for how many items the
`player obtained so that the player obtains satisfaction on a personal level. The system can utilize
`game scores, levels, status, etc. to perform better on triggering or obtaining items in some kinds of
`wagering games, such as bonus games, skill based wagering games, etc. (e.g., a level 5 group
`member may have a greater chance of obtaining certain items or performing well on certain items
`than a level 1 group member). … The system can provide players with tickets based on the number of
`items that a player account obtained during the group scavenger hunt game. By receiving more
`tickets, a player account would have a greater chance of winning the award. In some examples, if an
`item requires an event to be obtained multiple times, then the system could award tickets to player
`accounts based on the number of times that the player account completed the event for the item.
`Some tickets may be more valuable than others may (e.g., have values greater than one ticket).”
`¶ [0066]
`“In some embodiments, some achievements may be awarded based upon accumulation of other
`achievements or assets, such that the awarding of virtual assets is subject to a hierarchy. For example,
`collecting achievements such as ribbons may permit a player to be awarded a higher-level
`achievement, such as a medal, in accordance with one or more rule sets. In an example, collecting ten
`ribbons provides a player with a medal as an achievement, while further still, collecting ten medals
`awards the player a trophy, as an achievement or asset. Such hierarchy may be provided to players in
`a number of ways, including via gaming terminals or over the internet. Moreover, the rules set(s) of
`the system may further govern which players may win higher-level achievements. For example, in an
`embodiment, only one player may win a trophy (a higher-level achievement) even though all players
`are eligible to win lower level achievements. The player winning the trophy may satisfy certain
`criteria, for example, being the first one to win a certain number of lower level achievements. Other
`criteria may be employed as well.” ¶ [0096]
`
`To the extent this limitation is not explicitly disclosed, Supercell responds that it is inherent or
`obvious. Moreover, it would have been obvious to one of ordinary skill in the art to modify this
`reference so as to include this claim limitation in light of the knowledge possessed by one of ordinary
`skill in the art. Further, this claim limitation would have been obvious in light of numerous other U.S.
`patents, U.S. patent publications, articles, and products available at the time the asserted patent was
`
`12
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 12 of 32
`
`

`

`’439 Patent Claim 1
`
`[Element 1-H]
`(h) determining whether all
`the required game pieces have
`been provided to the first
`plurality of users, based on
`the allocation information;
`and
`
`
`
`Disclosure from Englman
`filed, and it would have been obvious to combine these references to a person of ordinary skill in the
`art. For example, see at least the corresponding claim elements in the respective charts, which are
`incorporated by reference as if fully set forth herein: World of Warcraft, Warhammer Online, Guild
`Wars 2, Ronen, Qiang, Bethke, Kane, Kobayashi, Forsaken World.
`
`Englman discloses (h) determining whether all the required game pieces have been provided to the
`first plurality of users, based on the allocation information.
`
`“The system can attribute scores, levels, status, etc. on a personal trophy case for how many items the
`player obtained so that the player obtains satisfaction on a personal level. The system can utilize
`game scores, levels, status, etc. to perform better on triggering or obtaining items in some kinds of
`wagering games, such as bonus games, skill based wagering games, etc. (e.g., a level 5 group
`member may have a greater chance of obtaining certain items or performing well on certain items
`than a level 1 group member). … The system can provide players with tickets based on the number of
`items that a player account obtained during the group scavenger hunt game. By receiving more
`tickets, a player account would have a greater chance of winning the award. In some examples, if an
`item requires an event to be obtained multiple times, then the system could award tickets to player
`accounts based on the number of times that the player account completed the event for the item.
`Some tickets may be more valuable than others may (e.g., have values greater than one ticket).”
`¶ [0066]
`“In some embodiments, some achievements may be awarded based upon accumulation of other
`achievements or assets, such that the awarding of virtual assets is subject to a hierarchy. For example,
`collecting achievements such as ribbons may permit a player to be awarded a higher-level
`achievement, such as a medal, in accordance with one or more rule sets. In an example, collecting ten
`ribbons provides a player with a medal as an achievement, while further still, collecting ten medals
`awards the player a trophy, as an achievement or asset. Such hierarchy may be provided to players in
`a number of ways, including via gaming terminals or over the internet. Moreover, the rules set(s) of
`the system may further govern which players may win higher-level achievements. For example, in an
`embodiment, only one player may win a trophy (a higher-level achievement) even though all players
`are eligible to win lower level achievements. The player winning the trophy may satisfy certain
`
`13
`
`Patent Owner Gree, Inc.
`Exhibit 2006 - Page 13 of 32
`
`

`

`’439 Patent Claim 1
`
`[Element 1-I]
`(i) allocating in a memory,
`the game item to the first
`group or at least one of the
`first plurality of users, when it
`is determined that all the
`required game pieces have
`been provided within a
`predetermined period of time
`during which the group event
`is taking place.
`
`
`
`Disclosure from Englman
`criteria, for example, being the first one to win a certain number of lower level achievements. Other
`criteria may be employed as well.” ¶ [0096]
`
`To the extent this limitation is not explicitly disclosed, Supercell responds that it is inherent or
`obvious. Moreover, it would have been obvious to one of ordinary skill in the art to modify this
`reference so as to include this claim limitation in light of the knowledge possessed by one of ordinary
`skill in the art. Further, this claim limitation would have been obvious in light of numerous other U.S.
`patents, U.S. patent publications, articles, and products available at the time the asserted patent was
`filed, and it would have been obvious to combine these references to a person of ordinary skill in the
`art. For example, see at least the corresponding claim elements in the respective charts, which are
`incorporated by reference as if fully set forth herein: World of Warcr